1 Final Draft Staff Report with Appendi ces For Proposed Amendments to Rule 4684 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

FINAL DRAFT STAFF REPORT

Proposed Amendments to Rule 4684 (Polyester Resin Operations)

August 18, 2011

Prepared by: Nichole Corless, Air Quality Specialis t

Reviewed by: Yousif Zardo, Air Quality Inspector

James Harader, Senior Air Quality Engineer George Heinen, Rule Development Supervisor Errol Villegas, Strategies and Incentives Manager Samir Sheikh, Director of Strategies and Incentive s

I. SUMMARY

A. Reasons for Rule Development and Implementation

The California Air Resources Board (ARB) and the Un ited States Environmental Protection Agency (EPA) classified the San Joaquin Valley Air Basin (SJVAB) as severe and extreme

non-attainment for the state and federal ozone stan dards, respectively. In accordance with Federal Clean Air Act (CAA) requirements for non-at tainment areas, the San Joaquin Valley Unified Air Pollution Control District (District) a dopted the 2007 Ozone Plan to establish a strategy for attaining the eight-hour ozone standar ds.

The ozone attainment strategy is comprised of regul atory and incentive-based measures to reduce emissions of nitrogen oxides and volatile or ganic compounds (VOC), a precursor of ground-level ozone. Rule 4684 (Polyester Resin Ope rations) controls VOC by limiting the VOC content of materials, specifying control system requirements, and requiring loss minimizations practices. On September 17, 2009 the San Joaquin Valley Unified Air Pollution Control District’s (District) Governing B oard amended Rule 4684 to satisfy

commitments in the District’s 2007 Ozone Plan and implement RACT requirements as recommended in the Control Techniques Guidelines (C TG) for Fiberglass Boat Manufacturing Materials (EPA-453/R-08-004) (Appendi x E). On January 26, 2010, the United States Environmental Protection Agency (EPA) found that the current Rule 4684 “strengthens the SIP and largely fulfils the releva nt Clean Air Act requirements.” However, EPA also determined that additional review was requ ired to ensure that RACT requirements are satisfied for fibreglass non-boat manufacturing operations, and suggested consideration of additional requirements through their Technical Support Documents (TSD). As such, EPA issued a limited approval/limited disapproval o f the rule (Federal Register Vol. 75, No.16 as 40 CFR Part 52). A copy of this Federal R egister publication is included as Appendix C of this Staff Report.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

2 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 These amendments will address the recommendations i n EPA’s Technical Support Document (TSD) and end the 18-month sanction clock associated with the EPA action.

B. Description of the Rule Development Project

The purpose of this rule development project is to amend Rule 4684 update rule language as identified in the TSD published by EPA in May 20 09 (Appendix D). According to the TSD, the District must consider revising the curren t monomer content limits to be as stringent as other California Air Districts to fulf ill RACT requirements. As part of those amendments, new rule definitions would also be adde d to clarify and support the monomer content limit changes. Also, in our continuing eff ort to provide excellent customer service to the affected stakeholders, amendments will also rem ove past deadlines in the current rule language to streamline the rule requirements and ai d in rule compliance.

C. Rule Development Process

As part of the rule development process, District s taff contacted operators and requested information to assess the impact of potential rule amendments to the VOC content limits of materials. Based on these conversations, the major ity of operators will not encounter problems complying with the draft amendments. Dist rict staff held a public review period and technical workgroups to allow public review and comment on the draft amendment language and this staff report. Comments received were incorporated into the proposed rule and final draft staff rule, as appropriate.

The proposed rule and final draft staff report were published and provided to affected sources and interested parties prior to the public hearing to consider the adoption of the rule by the District’s Governing Board. The propos ed amendments were scheduled to be presented to the Governing Board at their June 16, 2011 meeting for the public hearing to consider adoption.

II. CLIMATE CHANGE

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, multi-year program to reduce greenhouse gas (GHG) e missions in California, with the overall goal of restoring emissions to 1990 levels by the year 2020. In the coming years, ARB and the Legislature will be developing policies and programs to implement AB 32.

The District believes that the evidence and the rat ionale that climate change is occurring is compelling and convincing. In addition to the long -term consequences of climate change, the District is concerned with the potential ramifi cations of more moderate but imminent changes in weather patterns. The Valley depends he avily on agriculture for its economy and has developed agricultural practices based on t he last several decades of weather patterns. Unanticipated and large fluctuations in these patterns could have a devastating effect on the Valley’s economy.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

3 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 While there are many win-win strategies that can re duce both GHG and criteria/toxic pollutant emissions, when faced with situations tha t involve tradeoffs between the two, District staff believes that the more immediate pub lic health concerns that may arise from an increase in criteria or toxic pollutant emission s should take precedence.

III. BACKGROUND

EPA Recommendations

On January 26, 2010 EPA published a limited approva l and limited disapproval of revisions to the District portion of the California SIP in the Federal Register regarding VOC emissions from polyester resin operations. Und er authority of the CAA, as amended in 1990, this action simultaneously approve s local rules that regulate these emission sources and directs California to update r ule language.

EPA finalized a limited approval of the submitted r ule, as authorized in §110(k)(3) and §301(a) of the CAA; EPA also simultaneously finaliz ed a limited disapproval of a portion of the rule. Because of the limited disapp roval, sanctions will be imposed on the District unless EPA approves subsequent SIP rev isions within 18 months of the

effective date of their final action. These sancti ons will be imposed under §179 of the CAA according to 40 CFR 52.31. In addition, EPA mu st promulgate a federal implementation plan (FIP) under §110(c) unless EPA approves subsequent SIP revisions that update rule language within 24 month s of the effective date of this action. EPA’s final limited disapproval does not p revent the District from enforcing the current rule, as adopted by the Governing Board.

The TSD for EPA’s Notice of Direct Final Rulemaking recommends the following language updates:

1. Other California air districts have more stringe nt monomer content requirements than Rule 4684. The District must either lower spe cific monomer content limits to be as stringent as similar categories in other air districts or demonstrate that the more stringent limits are not economically or techn ologically feasible for the sources in the Valley.

2. Other California air districts require a 90% ove rall capture and control efficiency requirement for VOC control systems, compared to th e 85% requirement in Rule

4684. The District must either match other air dis tricts and not limit the use of these systems to continuous periods of operation or demon strate that the more stringent limit is not economically or technologically feasib le for the sources in the Valley.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

4 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 IV. CURRENT RULE 4684 AND PROPOSED AMENDMENTS

A. Current Rule 4684

Rule 4684 was adopted on May 19, 1994. The rule ha s undergone three amendments, with the last occurring on September 17, 2009. The last rule amendments incorporated the CTG monomer content limits as applicable to fib erglass boat manufacturing materials.

The purpose of the rule is to limit VOC emissions f rom polyester resin operations and from organic solvent cleaning, storage and disposal of s olvents and waste solvent materials associated with such operations. The rule applies to commercial and industrial polyester resin operations. Polyester resin operations is de fined in the rule as methods used for the production or rework of products by mixing, pouring , hand layup, impregnating, injecting, forming, winding, spraying, and/or curing with fibe rglass, fillers, or other reinforcement materials and associated cleanup.

Rule 4684 exempts low-emitting operations such as f acilities that use less than 20 gallons per month of polyester resin, provided the operator keeps the records required by the rule to demonstrate exemption status. The rule also exe mpts specialty applications such as cleaning of solar cells, laser hardware, scientific instruments, or high precision optics, and cleaning in laboratory tests and analyses, or bench scale or research and development projects from the organic cleaning material require ments.

The current Rule 4684 allows a general polyester re sins operator to choose one of three equivalent compliance methods:

• Use low-VOC polyester materials, ranging from 35% to 50% by weight monomer content, depending on whether the material is a res in or gel coat;

• Use resins containing vapor suppressant resulting in a weight loss from VOC emissions that does not exceed 60 grams per square meter of exposed surface during resin polymerization;

• Use a closed-mold system; or

• Operate an APCO-approved VOC emission control syst em that achieves an overall capture and control efficiency of at least 85 percent by weight.

Fiberglass manufacturing operators must comply with the recently adopted monomer content limits specified for fiberglass boat manufa cturing operations in the EPA CTG.

To minimize emissions by reducing overspray, Rule 4 684 requires that spray application of resins be performed using airless, air-assisted air less, high-volume low-pressure spray equipment, or electrostatic spray equipment. In li eu of using the specified spray equipment, the operator may comply by operating an APCO-approved VOC emission control system around the application operation, pr ovided the control system achieves an overall capture and control efficiency of at least 85 percent by weight.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

5 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 Rule 4684 requires operators to use organic solvent cleaning materials that contain no more than 25 grams/liter (0.21 pound/gallon) for al l types of cleaning operations. Also, the rule includes administrative requirements such as r ecordkeeping and test methods to demonstrate compliance with the emission standards of the rule.

For detailed requirements, please refer to the curr ent Rule 4684, which is available on the District’s website at www.valleyair.org.

B. Proposed Amendments to Rule 4684

As discussed in the TSD, current monomer content li mits and VOC control system effectiveness should be revised to be as stringent as other air districts to fulfill RACT requirements. District staff compared our limits t o those in other air districts and produced a draft, revised VOC limit table for resins and gel coats. The revised table was compared to current operator information from our Permits da tabase. Operators that would have to comply with the draft VOC limits were contacted. B ased on the research and industry contacts, operators will be able to comply with dra ft changes without encountering problems or incurring substantial costs. According to our conversations with the operators, they are either currently using coating that are compliant with the new limits, don’t use coating in the new categories that are be ing added, or can switch to compliant coatings without significantly impacting their oper ations.

The monomer content limits for polyester resin oper ations does not include changes to fiberglass boat manufacturing limits, because these limits were previously addressed in the last rule amendments. Staff proposes to make t he amendments effective on and after January 1, 2013 to allow time for rule disseminatio n and the operators to take any necessary compliance actions. As part of these ame ndments, new rule definitions would be added to clarify and support the monomer content limit changes. Also, in our continuing effort to provide excellent customer service to the affected stakeholders, proposed amendments would also remove past deadlines in the current rule language to streamline the rule requirements and aid in rule compliance.

The following specific changes are contained in the proposed amendments:

• Section 3.0 (Definitions) would include new defini tions of terms associated with new material categories in order to enhance the clarity and effectiveness of the rule. Definitions were added for the following terms: Cor rosion-Resistant Material; Filament Application; Filled Polyester Resin Material; Fille r; Fire Retardant Material; Fluid Impingement Technology; High-Strength Material; Lam ination Resin; Manual Application; Marble Resin; Non-Atomizing Spray Gun; Production Resin; Small Job; Solid Surface Resin; Specialty Gel Coat; Touch Up; and Tub/Shower Resin. For consistency, these definitions were primarily deriv ed from those found in other air

district rules and in 40 CFR 63.5935.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

6 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 • Section 5.0 (Requirements). Section 5.1, Table 1, would be added to specify the new

material VOC content limits that would be effective after January 1, 2013. This compliance date is to allow time for rule dissemina tion and for any existing stocks of older materials to be depleted. Existing material VOC limits would remain in effect until that date, however, to prevent any rule relaxation.

The proposed limits are the most stringent limits c urrently in place in any air district. The process for determining the following proposed lower monomer content limits is further discussed in Section X of this Staff Report . Because the limits have been in place for some time in other air districts, materia l availability is generally expected to be adequate and compliance with the rule should not po se a hardship to operators. Staff verified with operators that they are either curren tly using compliant materials, don’t use the specialty products, or can switch to such m aterials without significant impacts to their operations. These limits represent the m ost stringent limit in place in any air district, so the proposed rule should satisfy, if n ot go beyond, RACT for this category.

Table 1: Compliant Materials Weighted Average Monom er VOC Content

for Open Molding Resin and Gel Coat

Material Weight Percent Limit on and after January 1, 2013
a. General Purpose Resin

- Marble Resins 10% or 32 % as supplied, no fillers

- Solid Surface Resins 17%

- Tub/Shower Resins 24% or 35 % as supplied, no fillers

- Lamination Resins 31% or 35 % as supplied, no fillers b. Tooling Resin - Atomized (spray) 30%

- Non-atomized 39% c. Specialty Resin

- Fire Retardant Resin 38% - High Strength Materials 40%

- Corrosion Resistant Resin 48%

d. All Other Resin 35%SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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7 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 Table 1: Compliant Materials Weighted Average Monom er VOC Content

for Open Molding Resin and Gel Coat (continued)

Material Weight Percent Limit on and after January 1, 2013
e. Tooling Gel Coat 40% f. Pigmented Gel Coat

- White and Off White 30%

- Non-White 37%

- Primer 28% g. Clear Gel Coat

- Marble Resins 40%

- Other Resins 44% h. Specialty Gel Coats 48%

• Section 5.1.1.3 would be modified to lower the VOC emission limit of 60 grams per square meter to 50 grams per square meter when usin g a resin containing a vapor suppressant. This is level consistent with other C alifornia air districts and is currently achieved by Valley operators subject to this requir ement.

• Section 5.1.1.5.2 would be modified to remove the reference to “continuous operation”, as required by EPA, since other districts did not h ave this qualifying language in their rules. This language was ambiguous as it might hav e been interpreted as the condition under which the control system would eith er be operated or tested. Section 6.1.1.4 already required that the system would have to be operated “during periods of emission producing activities” so this proposed ame ndment does not change the stringency of the rule or affect Valley operators. Based on staff conversations with EPA, as a clarification, a reference to the test me thods in Section 6.2 has been added.

Section 5.1.1.5.2 would also be modified in respons e to EPA comments, to change the emission control system limit from 85% control effi ciency to 90% control efficiency to reflect the limit in other air districts. Operator s who are currently using an emission control would either be able to comply with one of the other options, such as meeting the proposed monomer content limits, or are boat ma nufacturers and therefore subject to the fiberglass boat manufacturing limits instead . One operator recently replaced their carbon adsorption system with a regenerative thermal oxidizer (RTO) system and is still testing the efficiency. Typical RTO VOC c ontrol efficiency is much higher than carbon adsorption systems, so the change in rule la nguage should not present a problem. The operator should also be able to compl y under other sections of the rule. In general, operators using a VOC emission control system would be able to comply with the amended rule requirements using their curr ent equipment.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

8 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 • Section 5.1.1.6 would be added to address special considerations for minor touch ups, repairs, and small jobs. This allowance is similar to other air districts and was requested by stakeholders to minimize material wast e. Such material can have up to 10% higher monomer for proper operation in this equ ipment. The proposed new section would allow operators to use hand-held atom ized spray equipment for small projects, up to two gallons per day per facility. This allowance is needed because non-atomized spray equipment is not available for s mall jobs that do not require large amounts of resin or gel coat. Non-atomizing equipm ent is used for large products and typically has long resin or gel coat hoses that can contain several gallons of resin. Use of this equipment for touch up, repairs, and small jobs and would lead to waste or inefficient operations. Small jobs would include m inor operations like attaching supports to allow for custom mounting of special-or der hardware.

Some districts, such as Bay Area address these situ ations by stating the equipment to must be limited to equipment with one quart reservo irs, but do not specify a limit on the total material used per day. Therefore, the propos ed rule language would be more stringent by establishing a limit in the amount of material that can be used per day at a facility. Recordkeeping for this allowance would a lso be added to Section 6.1 to allow

verification and enforcement.

• Section 5.2 would be clarified by removing languag e referring to old implementation dates for fiberglass boat manufacturing operations. Compliance with these sections has been required of applicable operators since Jan uary 1, 2011, so removal of the dates does not affect rule stringency.

V. VOC EMISSION AND REDUCTIONS

According to the District’s 2007 Ozone Plan, the so urce category for Polyester Resin Operations (S-IND-3) was not recommended as a contr ol measure for VOC reduction and

no additional reductions were available. Since the federal CAA requires ozone nonattainment areas to implement RACT, the proposed amendments are required to meet the stringency of other California air districts.

The ARB emissions inventory shows total VOC emissio ns of only 0.38 tons of VOC per day for this source category, based on actual mater ial usage and VOC contents. District

staff believes that further VOC emissions reduction s as a result of this rulemaking project will be insignificant since most operators are alre ady in compliance with the proposed amendments or do not use the specialty categories m aterials which are being modified. For the most common categories, the difference in V OC content is approximately 14% so if operators were not already complying with the pr oposed limits, the maximum reduction would be 0.05 tons of VOC per day. Given that the amount of operators in compliance and that some of the operators are fiberglass boat manufacturers who are already in compliance with the previously adopted CTG limits, the actual emission reduction isSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

9 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 expected to be much less and therefore not signific ant and are not being claimed for this rule amendment project. No SIP commitment exists f or this project so no impact is expected on attainment progress.

VI. COST EFFECTIVENESS ANALYSIS

Pursuant to California Health & Safety Code Section 40920.6(a), the District is required to analyze the cost effectiveness of new rules or rule amendments that implement Best Available Retrofit Control Technology (BARCT) or pl anning requirements to incorporate all feasible measures. The proposed amendments to Rule 4684 would only add federal RACT requirements but not BARCT or all feasible measures , and are therefore not subject to the cost effectiveness analysis mandate. Given that op erators are generally complying with the new limits currently and there are no significant e mission reductions or compliance costs expected from these rule changes, a cost effectiven ess analysis has not been performed.

VII. SOCIOECONOMIC ANALYSIS

Pursuant to California Health and Safety Code (CH&S C) 40728.5(a), “Whenever a district intends to propose the adoption, amendment, or repe al of a rule or regulation that will significantly affect air quality or emissions limit ations, that agency shall, to the extent data are available, perform an assessment of the socioec onomic impacts of the adoption, amendment, or repeal of the rule or regulation. Th is section does not apply to the adoption, amendment, or repeal of any rule or regul ation that results in any less restrictive

emissions limit if the action does not interfere wi th the district's adopted plan to attain ambient air quality standards, or does not result i n any significant increase in emissions.”

This rule-amending project does not significantly a ffect air quality and no significant emission reductions are expected or claimed. Although, some emissions limitations are amended, the revisions are not considered significant, since the limits have been in place for some time in other air districts and compliant material availabi lity is expected to be adequate.

Based on discussions with operators, the changes do not create a significant change to their operations or economic situation since they are alr eady using compliant materials or do not use the specialty materials that are being impacted . Therefore, staff concludes that, if a detailed socioeconomic analysis were conducted, the re would be no significant socioeconomic impact from this rule.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

10 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 VIII. ENVIRONMENTAL ASSESSMENT

Pursuant to the California Environmental Quality Ac t (CEQA), staff investigated the likely environmental impacts of the proposed amendments to Rule 4684. Adoption of the proposed amendments would lower allowable VOC emiss ions limits from polyester resin operations, potentially having a positive impact on air quality. Because operators are generally already complying with the proposed limit s, there are no foreseeable changes in operating practices resulting from implementation o f these changes that would impact environmental resources, other than air quality. T herefore, staff concludes that there is no

substantial evidence in the whole record before the District that the proposed amendments would cause any adverse environmental ef fects. The District finds that the project is exempt per the general rule that CEQA ap plies only to projects which have the potential for causing a significant effect on the e nvironment (CCR §15061(b)(3)). For these reasons, staff is proposing to file a Notice of Exe mption upon Board adoption of the proposed amendments to Rule 4684.

IX. RULE CONSISTENCY ANALYSIS

As required by California Health & Safety Code Sect ion 40727.2, District staff conducted a rule consistency analysis in Appendix B. That cons istency analysis compared the elements of the proposed version of Rule 4684 with the corresponding elements of other District rules, federal regulations and guidelines that apply to the same source category or type of equipment. Based on that analysis, Distric t staff found that the proposed

amendments to Rule 4684 would not conflict with fed eral rules, regulations, or policies covering similar stationary sources.

X. REASONABLY AVAILABLE CONTROL TECHNIQUES (RACT) A NALYSIS

This analysis is necessary for any rule that effect s ozone, found in the Ozone plan. EPA partially disapproved part of Rule 4684 in January 2010 because it did not meet their requirements for RACT. The incorporated proposed a mendments to the District Rule 4684 meets, or exceeds RACT requirements.

RACT Discussion

The Clean Air Act (CAA) Section 182(b)(2) states th at ozone attainment plans shall assure that RACT for volatile organic compounds (VOC) is a pplied at certain sources. Section 182(f) extends federal RACT requirements to NOx rul es and major NOx sources. District Rule 4684 is a VOC rule, therefore underwent a RACT analysis during this rule amending project. A RACT analysis requires an examination o f a rule against Federal rules, regulations, and technology 4684 was compared to fe deral and state regulations andSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

11 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 guidance in the 2009 RACT SIP, Chapter 4: Rule Anal ysis. The following is a discussion of that analysis.

District staff compared emission limits, optional c ontrol requirements, and work practice standards in District Rule 4684 to comparable requi rements in rules from the other Air

Districts in California nonattainment areas. The an alysis shows that the current Rule 4684 was less stringent when compared to specific requir ements, discussed below, in other

Districts’ rules.

District staff also reviewed the Technical Support Document that EPA issued discussing the limited approval/limited disapproval of Rule 46 84. Staff proceeded to incorporate the following changes that were proposed by EPA:

• Lower VOC monomer content limits to match other ai r districts.

• Increase the control efficiency requirement for VO C emission control systems.

• Add definitions of terms associated with the new m aterial categories.

• Modify Section 5.1.1.2 to lower the allowable VOC emissions when using a vapor suppressing resin.

• Modify Section 5.1.1.4.2 to remove the mention of “continuous operation”.

District staff evaluated Rule 4684 in comparison wi th equivalent California air district rules and the proposed amendments will make Rule 4684 as comparable to the most stringent limit in other air districts. Specifically, the fo llowing air district rules were evaluated, as

cited in the TSD:

• South Coast Air Quality Management District (SCAQM D) Rule 1162

• Bay Area Air Quality Management District (BAAQMD) Rule 8-50

• Sacramento Metropolitan Air Quality Management Dis trict (SMAQMD) Rule 465

• Ventura County Air Pollution Control District (VCA PCD) Rule 74.14

• Mojave Desert Air Quality Management District (MDA QMD) Rule 1162

The following table summarizes the proposed limits and indicates where the limit was found to be the most stringent and the year the lim it went into effect in the particular district. The majority of the limits originate fro m the SCAQMD Rule 1162 which were effective since 2002. Subsequent to that time, oth er air districts have incorporated similar limits, as shown in Table 2. The long-term require ment and wide-spread acceptance of these limits indicates their general commercial ava ilability and applicability. This was also borne out by staff conversations with Valley operat ors who verified that they are currently using these materials.

Tooling resin and tooling gel coat limits were not found in other districts’ rules but are mentioned in the Fiberglass Boat Manufacturing CTG and are therefore considered to be RACT for this material type.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

12 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 Table 2: Comparison of Proposed Compliant Materials Weighted Average Monomer VOC

Content With Similar Categories in Other California Air Dis tricts’ Rules

Material Proposed Weight Percent

Limit Districts with similar limits (effective

date of the limits in that air district)
a. General Purpose Resin

- Marble Resin 10% or 32% as supplied, no fillers

SCAQMD (2002); BAAQMD (2010); VCAPCD (2005); MDAQMD (2007) - Solid Surface Resin 17%

- Tub/Shower Resin 24% or 35% as supplied, no fillers

- Lamination Resin 31% or 35% as supplied, no fillers
b. Tooling Resin - Atomized (spray) 30% Fiberglass Boat Manufacturing CTG - Non-atomized 39%
c. Specialty Resin

- Fire Retardant Resin 38% SCAQMD (2002); BAAQMD (2010); VCAPCD (2005); MDAQMD (2007)

- High Strength Materials 40% SCAQMD (2002); BAAQMD (2010); VCAPCD (2005) - Corrosion Resistant Resin 48% SCAQMD (2002)

d. All Other Resin 35% SCAQMD (2002); BAAQMD (2010); VCAPCD (2005); MDAQMD (2007)

e. Tooling Gel Coat 40% Fiberglass Boat Manufacturi ng CTG

f. Pigmented Gel Coat

- White and Off White 30% SCAQMD (2002); BAAQMD (2010); VCAPCD (2005); M.DAQMD (2007) - Non-White 37%

- Primer 28%

g. Clear Gel Coat

- For Marble Resins 40% SCAQMD (2002); VCAPCD (2005); MDAQMD (2007)

- For Other Resin 44% SCAQMD (2002); BAAQMD (2010); VCAPCD (2005); MDAQMD (2007)

h. Specialty Gel Coat 48% SCAQMD (2002); BAAQMD (2010); VCAPCD (2005); MDAQMD (2007)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

13 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 The MDAQMD and BAAQMD have lower limits for Corrosi on Resistant Resin than the SCAQMD, depending on the application method, as sho wn in Table 3.

Table 3: Comparison of Corrosion Resistant Resin L imits

Material Category Monomer VOC

Content Limit District (effective date of the limit)

- Corrosion Resistant Resin 48% SCAQMD (2002) -- Non-atomized 46.2% MDAQMD (2007) -- Non-atomized 46% BAAQMD (2010) -- Filament Application 42% BAAQMD (2010); M DAQMD (2007) -- Manual Application 40% BAAQMD (2010); MDA QMD (2007)

It would normally be reasonable to lower a material ’s VOC content for operations which do not require lower viscosity to aid in application. However, staff received a comment from an operator that corrosion resistant resins must ha ve a sufficient number of styrene molecules to complete all of the desired number of cross-links and create the required corrosion-resistance and mechanical properties. Th e required styrene is contained in the VOC used in the resin system and becomes an integra l part of the final cured composite. Reducing the VOC levels to the BAAQMD and MDAQMD wo uld reduce the styrene levels below what is required to form the necessary cross- links and would make such operations technologically infeasible in the Valley.

This concern is supported by the SCAQMD rule histor y which originally set the Corrosion
Resistant Resin limit at 30%. SCAQMD determined th at the low limit was technologically infeasible for this category and settled on a 48% l imit to account for the special physical
and chemical considerations of this material. MDAQ MD staff confirmed that they did not have an operation in this category and that no oper ators had used this material, so their limits cannot be considered to be an achieved-in-pr actice RACT standard. Staff therefore proposes to apply the SCAQMD limit for this categor y, regardless of application method. This limit would avoid an extreme impact on the exi sting Valley facilities which might otherwise be unable to operate under the lower limi ts. This change represents a 2% decrease from the existing limit, can be accomplish ed without significant impacts to existing operations, and has been demonstrated to b e achieved-in-practice RACT for this category by operators in the South Coast and the Va lley.

The 90% VOC control efficiency requirement and the allowance for use of a vapor suppressed resin with a fifty (50) gram per square meter emission limit originated in SCAQMD Rule 1162 and have been subsequently adopted by other air districts. Like the proposed material VOC limits, Valley operators who would be subject to these proposed limits are already in compliance with the SCAQMD li mits.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Rule 4684 August 18, 201 1

14 Final Draft Staff Report with Appendices For Proposed Amendments to Rule 4684 Because of the age of the current air districts’ ru les, none of the other air districts have incorporated all of the limits which were found to be the most stringent. By incorporating all of the most stringent limits of the air distric ts and the CTG, Rule 4684 would be the most stringent rule possible for this category. Th erefore, District staff concludes that the proposed amendments to Rule 4684 would satisfy, if not go beyond, RACT requirements for all polyester resin 

### operations

.

XI. REFERENCES

1. US EPA. 40 CFR Part 52, Federal Register, Vol. 7 5, No. 16, January 26, 2010. [EPA–R09–OAR–2009–0475; FRL–9104–7]

2. US EPA. Technical Support Document for EPA’s Ana lysis of San Joaquin Valley Unified Air Pollution Control District’s Rule 4684, Polyester Resin Operations, May

2009.

3. South Coast Air Quality Management District (SCA QMD) Rule 1162

4. Bay Area Air Quality Management District (BAAQMD ) Rule 8-50

5. Sacramento Metropolitan Air Quality Management D istrict (SMAQMD) Rule 465

6. Ventura County Air Pollution Control District (V CAPCD) Rule 74.14

7. Mojave Desert Air Quality Management District (M DAQMD) Rule 1162